https://www.taxtmi.com/caselaws?id=799967 Section 92CA(3) of the Income-tax Act requires transfer-pricing determinations to demonstrate due consideration of the assessee's submissions and to record reasons supporting the determination. Consideration of written replies alone is insufficient where the order neither identifies the contentions considered nor provides supporting reasons. Failure to afford a personal hearing, where required, also undermines the validity of the determination. An unreasoned transfer-pricing order issued without a personal hearing cannot be sustained and must be redetermined through a reasoned order after affording the assessee an opportunity of personal hearing in accordance with law. en-us Fri, 25 Sep 2026 00:00:00 +0530 Tue, 29 Sep 2026 08:34:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799967 Section 92CA(3) of the Income-tax Act requires transfer-pricing determinations to demonstrate due consideration of the assessee's submissions and to record reasons supporting the determination. Consideration of written replies alone is insufficient where the order neither identifies the contentions considered nor provides supporting reasons. Failure to afford a personal hearing, where required, also undermines the validity of the determination. An unreasoned transfer-pricing order issued without a personal hearing cannot be sustained and must be redetermined through a reasoned order after affording the assessee an opportunity of personal hearing in accordance with law. Case-Laws GST Fri, 25 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799967